In the Federal Aviation Act of 1958, a complex multi-step approval/certification process was established for the Federal Aviation Administration (FAA) to follow to ensure that civil aircraft meet minimum safety requirements. These regulations are found in 14 Code of Federal Regulations (CFR), which comprise the Federal Aviation Regulations (FARs).
The regulatory requirements that civil aircraft must meet depend on the type of aircraft involved (i.e., light airplanes, large multi-passenger airplanes, helicopters, etc.) and the aircraft's intended use (i.e., private, crop dusting, airline, external load-bearing helicopters, etc.). The basic premise of the regulations is that the FAA must certify each aircraft with an eye toward assuring adequate testing so as to prevent a component, a modification, or an aircraft from becoming a potential hazard to passengers or to others. Except for “public aircraft” (i.e., those operated by the federal, state, or local government), all civil aircraft must be approved by the FAA before they can be placed into any service. To acquire the necessary approvals, the builder or the operator must demonstrate to the FAA, via the multi-step approval process, that the aircraft complies with appropriate regulatory requirements.
The FAA conducts all of the various testing steps in the approval process. To that end, the FAA reviews and approves designs, test and production hardware, and test plans; witnesses tests; and approves test data. The primary responsibility for carrying out the necessary demonstrations of compliance lies with aircraft manufacturers and operators. Manufacturers perform some of the approval steps and aircraft operators perform the others.
Aircraft type certification is the process by which the FAA evaluates and approves aircraft type design data against designated airworthiness standards, culminating in the initial issuing of a Type Certification (TC). It is a prerequisite for the issue of a Certificate of Airworthiness (CoA) for an individual aircraft. Subsequently, an aircraft manufacturer may amend the TC or apply for supplemental type certifications (STCs). STCs are issued when the manufacturer proposes major changes.
Aviation Safety Inspectors (ASIs) make conformity inspections as a part of two higher-level processes—Type Certification and Production Certification. A conformity inspection is a process of assigning suitable testing of the subject assembly, reviewing the results of the assigned testing, and certifying the part as air-worthy. A conformity inspection may satisfy either of these processes. Conformity inspections are generally required for the following purposes:                (a) Conformity inspection on Prototype Parts, Installations or Aircraft;        (b) Conformity inspection on Test Articles and Test Set-ups;        (c) Ground Inspections and Type Inspection Authorizations conducted on prototype aircraft, major modifications and STCs;        (d) Conformity inspection on production parts, assemblies or aircraft;        (e) Engine tear down inspections; and        (f) Bilateral conformity inspections performed for other CAA authorities.        
The FAA conducts Conformity Inspections during the manufacturing phase of prototype aircraft to:                (a) Verify and provide objective documentation to the FAA that test articles, parts, assemblies, installations, functions and test setups conform to the design and attributes that are specified;        (b) Provide the basis which enables the Manufacturing Inspector or designee to accept an FAA Form 8130-9, Statement of Conformity prior to turnover of the aircraft to Flight Test as required by FAR 21.33(a)(1) and 21.35(a)(3);        (c) Provide part of the basis for granting a Production Certificate (upon issuance of the Type Certificate) per FAR 21.135 and 21.153;        (d) Provide part of the basis which enables the Manufacturing Inspector or designee to issue and maintain an Experimental Certificate of Airworthiness for the prototype aircraft prior to flight as required by FAR 21.191, FAR 21.193, FAR 21.195, FAR 21.441;        (e) Provide part of the basis that enables the Manufacturing Inspector to issue a Standard Certificate of Airworthiness on a prototype aircraft after issuance of a TC/STC/PC; and        (f) Ensure any process/manufacturing concerns that are raised during the manufacturing/assembly process are corrected.        
The FAA also issues Type Acceptance Certificates (TACs), which have the force of a TC, for aircraft imported from a recognized country and TCs for aircraft imported from a non-recognized country.
Type certification (including supplemental type certification and other approval of major modifications) of an aircraft, aircraft engine, or propeller involves:                (a) Prescribing appropriate design standards and requirements;        (b) Ensuring that the product design is proven to meet the design standards, through competent and adequate ground tests, engineering analysis and flight tests;        (c) Checking that the test articles, when manufactured, conform to the design requirements;        (d) Ensuring that the Aircraft Flight Manual (AFM) and associated operating aspects are satisfactory;        (e) Accepting the maintenance manual and approving the Airworthiness Limitations Section of the maintenance manual (if applicable); and        (f) Ensuring that the manufacturer has satisfactory arrangements in place for continuing airworthiness control, defect reporting and supply of service documents.        
Over what is typically a three to five year process, the manufacturer must supply the FAA with detailed analyses as well as produce a prototype of the aircraft. Because the FAA cannot perform all of the analysis necessary to examine the prototype, the Federal Aviation Act of 1958 allowed the FAA to delegate activities, as the agency deems necessary. The FAA delegates activities to approved private persons, known as designees, employed by aircraft manufacturers to perform such analysis. Although paid by the manufacturers, these designees act as surrogates for the FAA in examining aircraft designs, production quality, and airworthiness. The FAA is responsible for overseeing the designees' activities and determining whether the designs meet the FAA's requirements for safety.
During type certification (TC) programs, the applicant's designated engineering representative (DER) generates a request for conformity (RFC), a FAA Form 8120-10. A request for conformity is the notification to the FAA that a conformity inspection is necessary. The request for conformity is typically routed through the Aircraft Certification Office (ACO) for approval; to the manufacturing specialist (in some locations) for tracking and routing; to the Manufacturing Inspection District Office (MIDO) principal inspector (PI) for review; and finally to the designated inspection representative for accomplishment of the inspection. The same process, in reverse, returns a completed conformity request through the same personnel before final closure.
The functional roles and responsibilities for designees are set forth in FAA Order 8110.37 for Designated Engineering Representatives and 8130.28 for Designated Manufacturing Inspection Representatives, Designated Airworthiness Representatives, and Organizational Designated Airworthiness Representatives. The ACO defines the method for tracking all conformity requests and maintaining a master list. The DER coordinator will control any tracking performed by the applicant on behalf of the FAA. In general, the criteria for determining ACO and MIDO involvement in requests for conformity inspections has been based on previous designee performance, applicant experience, designee expertise, part criticality, and the history of unsatisfactory/satisfactory findings, as referenced in FAA Order 8110.4A.
FIG. 1 is an information flow chart portraying the existing process for an FAA request for conformity (RFC) or a type inspection authorization (TIA). FIG. 1 depicts a circuitous process of conformity inspections involving several cooperating parties in communication and negotiation.
Conformity inspections are required to verify that an aircraft component or modification conforms to the data submitted to the FAA, and that the product being certificated complies with the Type design. These inspections physically compare the component or modification to the engineering specifications, drawings, and the airworthiness standards. Conformity inspections are initiated by filling out FAA Form 8110-1, Type Inspection Authorization or FAA Form 8120-10, Request for Conformity, and submitting it to the MIDO through the ACO project engineer. Conformity inspections are recorded and reported on FAA Form 8100-1, and FAA Form 8130-3 is completed if required.
A process 60 of requesting a conformity inspection begins when an Aviation Safety Engineer (ASE) or a Designated Engineering Representative (DER) receives a request for an inspection at a block 63. Either an FAA Form 8120-10 (RFC), or an FAA Form 8110-1 (TIA), serves as the internal FAA document to track the progress toward certification. At a block 69, the Aircraft Certification Office (ACO), the Manufacturing Inspection District Office (MIDO), or the Certificate Management Office (CMO) examines the form, approves it, and passes it to either and ASE or DER to request the inspection. The ASE or DER will review the document for completeness and apparent inconsistencies. If forms are appropriate, then the request is logged into the FAA system within the ACO at the block 69. FAA Designated Regulatory Office (DRO or FAADRO) might stand-in for the ACO.
Logging the request for inspection into the FAA notifies the MIDO or CMO that the application is in the system. The MIDO or CMO is included in the coordination process for reviewing all RFCs and TIAs. After the ACO/MIDO/CMO review the RFC or the TIA, either a MIDO or a CMO tracking number will be assigned to each form. Only with this tracking number do the forms become FAA-approved. In the course of the conformity process, there may be several revisions and retesting iterations under a single request and, therefore, a single FAA project number. Usually there is one FAA project number, but numerous conformity requests issued under that project number and the MIDO or CMO tracking number is a sequential number used for tracking each request. All RFCs and TIAs must be reviewed and approved by the ACO or authorized DER before release.
At a block 72, the applicant performs a conformity inspection. Depending upon whether the applicant seeks a statement of conformity for a part or an installation, the applicant then presents the inspection documentation to a conformity inspector at either a block 75 for parts or a block 78 for installation. The applicant selects an appropriate conformity inspector. The Conformity Inspector is either an Aviation Safety Inspector (Manufacturing), an FAA authorized Designated Manufacturing Inspection Representatives (DMIR), or a manufacturing Designated Airworthiness Representatives (DARs). FAA Manufacturing Aviation Safety Inspectors are located at various MIDOs throughout the certifying directorate. When a conformity inspection is conducted outside the certificating directorate, an FAA Form 8120-10 or FAA Form 8110-1 (with all pertinent information) are forwarded by the Manufacturing Inspection Specialist to the MIDO being requested to conduct the conformity. Once the inspection has been delegated, it is the responsibility of the ASI or Designee assigned to the conformity inspection to contact the ASE/ASI project manager for resolving any questionable items.
At a block 81, the MIDO, CMO and ACO will track the initiation and completion of the Conformity Inspection Record (CIRs) and TIAs. Each ASI periodically follows-up with their designees to ensure there are no problems and that each CIR or TIA is completed on time. The purpose of checking the status is to ensure that the designees are completing the required documentation in time for Type Certification or Part Certification approval. Conformity requests may be coordinated directly between district offices within the certificating Directorate.
The approved RFC or TIA is forwarded to the appropriate MIDO/CMO/CAA/Designee. The RFC can be sent by FAX, electronic mail, or regular mail—whichever way is most favorable to the project schedule completing the conformity process 60.
As is evident, the process 60 is both long and requires many people in official capacities to be aware of the status of the process. Because the process 60 is currently paper-based, it lacks an easy means of simultaneously reporting the application status to each of the interested parties.
Traditionally, the collection, assembly, compiling, and routing of an RFC has been a tremendously laborious task. The RFCs have all been paper printouts with paper endorsements. As a result, the process has been lengthy and labor intensive. Only one party holds the RFC package at any given time and only the holder of the RFC package accurately knows the status of any RFC. Where testing data is a part of the required content of the request, the applicant must unite the date to the administrative application. As a result of adherence to such a paper-based process, several inefficiencies and opportunities for misplacement of paper are introduced.
There exists, therefore, an unmet need for an automated means of assembly, promulgation, and review of requests for conformity.